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WESTERN MINING ACTION PROJECT <br />Roger Oynn, Esq.. <br />Jq i•ev C. Parsons, Esq. <br />P.O. Box 349 <br />440 Main Street, Suite 2 <br />Lyons, CO 80540 <br />(303) 823 -5738 <br />Fax (303) 823 - 5732 <br />w!Pa_ rh;i-c.ora <br />via email <br />July 24, 2009 <br />Valois Shea <br />U.S. Environmental Protection Agency Region 8 <br />8P -W -GW, UIC <br />1595 Wynkoop Street <br />Denver, CO 80202 <br />sh ea.valois:(,i)epa.�, , ov <br />RE: Proposed Underground Injection Control Program (UIC) Pen (Pen Number: <br />CO51237- 08412). <br />Dear Ms. Shea, <br />Thank you for the opportunity to comment on your agency's proposal to issue an <br />Underground Injection Control Program (UIC) Permit (Pemiit Number: CO51237- 08412) for <br />Pow.ertech (USA) Incorporated's proposed aquifer pump test in the Fox Hills Aquifer in Weld <br />County, Colorado. As discussed herein, the draft permit cannot be issued as proposed. At a <br />minimum, substantial additional information is required to demonstrate the ability of the permit <br />applicant to protect underground sources of drinking water. This information includes additional <br />baseline data on the water quality of both the injectate and the receiving water. In addition, the <br />permit applicant should be required to demonstrate that the substantial historic exploration <br />drilling in the area of the proposed permit will not result in contamination of adjacent aquifers, <br />including underground sources of drinking water. Lastly, the EPA's permit processing exercise <br />should be better coordinated with the required state permitting process for the proposed <br />underground injection activities. <br />We note that various permit numbers are used in various documents. making it unclear to the public as to which <br />permit is under review. The Public Notice and Statement of Basis and Purpose show permit No. CO51237- 08412. <br />whereas the Draft Permit cites permit No. CO5123 08408. Still further, the text of the Draft Permit states that <br />"[t]he EPA permit number the UIC Program Director ... has assigned to this permit is CO51237-08404." Draft <br />Permit at 2. Lastly, the bottom margin of each page of the Draft Permit lists "Petroglyph Energy, Inc., UIC Class V <br />Permit No. CO51 22 1- 00000." Thus, in various places, the EPA has listed no less than 4 different permit numbers in <br />the materials. At a minimum, this is confusing to the public, and at worst, renders the public notice insufficient, and <br />requires re- notice of the permit application to the public. <br />